For EPA Use Only ID # ______________

SECTOR _________________________

Under the Clean Air Act and the international treaty to protect the ozone layer 

(the Montreal Protocol on Substances that Deplete the Ozone Layer), the 

production and import of methyl bromide was phased out in the United States on 

January 1, 2005. This application seeks information to support a U.S. request to 

produce and import methyl bromide for certain critical uses and circumstances 

beyond this 2005 phaseout date.

The information in this application will be used to review whether your use of 

methyl bromide is "critical" because no technically and economically feasible 

alternatives are available. In order to estimate the loss as a result of not having 

methyl bromide available, EPA needs to compare data (yields, crops/crop 

groupings, prices, revenues and costs) for your use of methyl bromide with uses 

of alternative pest control regimens. 

EPA Form # 4900-136 Pre Plant

Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide 

information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize 

technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining 

information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions 

and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review 

the collection of information; and transmit or otherwise disclose the information. Public reporting burden for this collection of 

information is estimated to average 38 hours per response and assumes a large portion of applications will be submitted by 

consortia on behalf of many individual users of methyl bromide. An agency may not conduct or sponsor, and a person is not 

required to respond to, a collection of information unless it displays a current OMB control number.

The information contained in this application is critical to process and assess the need for methyl 

bromide. Filling out this application in its entirety will bolster the U.S. government's ability to 

strengthen the nomination package for the international review boards. 

OMB Control # 2060-0482, Expires 6/30/2015

WHY IS THIS 

INFORMATION 

NEEDED? 

2013 Application for Critical Use Exemption of Methyl Bromide 

for Pre Plant Use in the United States in 2016 and 2015

Click on the Instructions tab located at the bottom of the screen for additional information.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460
WHO 

APPLIES?

WHAT 

INFORMATION IS 

REQUIRED?

HOW DO 

I APPLY?

WHEN IS THE 

INFORMATION 

NEEDED?

Mailing Address for applications being submitted 

by mail directly to the EPA:

Address for applications being sent by courier or nonU.S. Postal overnight express delivery to the EPA:

US Environmental Protection Agency US Environmental Protection Agency

Methyl Bromide Critical Use Exemption Methyl Bromide Critical Use Exemption 

Office of Air and Radiation Office of Air and Radiation

Stratospheric Protection Division (6205 J) Stratospheric Protection Division

1200 Pennsylvania Ave, NW 1310 L Street, NW, Suite 1047E

Washington, DC 20460 Washington, DC 20005

INSTRUCTIONS

The information provided by you in this application will be used to evaluate the requested methyl bromide use. The U.S. and other countries that are 

parties to the Montreal Protocol On Substances That Deplete The Ozone Layer decided that: "a use of methyl bromide should qualify as "critical" only

if the nominating Party determines that:

(i) The specific use is critical because the lack of availability of methyl bromide for that use would result in a significant market disruption; and 

(ii) There are no technically and economically feasible alternatives available to the user that are acceptable from the standpoint of environment and 

health and are suitable to the crops and circumstances of the nomination ..." 

EPA Form # 4900-136 Pre Plant

HOW CAN I 

RECEIVE 

ADDITIONAL 

INFORMATION?

Critical use exemptions are valid for only one year and do not renew automatically. Users desiring to obtain an exemption for 

2016 must apply to EPA. Because of the latest changes in registrations, costs, and economic aspects for producing critical use 

crops and commodities, all applicants will be required to fill out the application form completely. If these Worksheets are not 

submitted, EPA will not include the application in the U.S. nomination submitted for international consideration. 

When submitting an application electronically, you should also sign Worksheet 1 and email or fax it to:

202-343-2338

If you anticipate that you will need methyl bromide in 2016 because you believe there are no technically and economically

feasible alternatives, then you should apply for the critical use exemption. This application may be submitted either by a 

consortium representing multiple users or by individual users. We encourage users with similar circumstances of use to submit 

a single application (for example, any number of pre plant users with similar soil, pest, and climactic conditions can submit a 

single application.)

If a consortium is applying for multiple methyl bromide users, the economic data should be for a representative or typical user 

within the consortium unless otherwise noted. If economic or technical factors (such as size of the farm) affecting the ability of 

this "representative user" to use alternatives are significantly different than other users in the consortium, more than one 

application should be submitted to reflect these differences.

Please contact your local, state, regional or national commodity association and/or state representative agency to find out if they

plan on submitting an application on behalf of your commodity group.

IS MY 

INFORMATION 

CONFIDENTIAL?

If you have general questions about this application call the Stratospheric Ozone Hotline at:

1-800-296-1996

More information is also at http://www.epa.gov/ozone/mbr

WHERE DO I 

SUBMIT THE 

APPLICATION?

You may either complete an electronic (Microsoft Word or Excel) or a printed version of the application. Please fill out each 

section in the application as completely as possible. If you are completing the printed version and need extra space you may

attach additional sheets as needed.

Information covered by a claim of confidentiality will be disclosed by EPA only to the extent, and by means of the procedures set 

forth under 40 CFR Part 2 Subpart B; 41 FR 36902, 43 FR 400000. 50 FR 51661. If no claim of confidentiality accompanies the 

information when it is received by EPA, it may be made available to the public by EPA without further notice to the applicant.

Electronic Address for applications: arling.jeremy@epa.gov

Applicants submitting their application via e-mail assume responsibility for the confidentiality of the electronic message 

transmission.

This application must be postmarked to the EPA address below no later than August 29.

OMB Control # 2060-0482, Expires 6/30/2015

The applicant may assert a business confidentiality claim covering part or all of the information in the application by placing on 

(or attaching to) the information, at the time it is submitted to EPA, a cover sheet, stamped or typed legend, or other suitable 

form of notice employing language such as trade secret, proprietary, or company confidential. 

Allegedly confidential portions of otherwise non-confidential documents should be clearly identified by the applicant, and may be 

submitted separately to facilitate identification and handling by EPA. If the applicant desires confidential treatment only until a 

certain date or until the occurrence of a certain event, the notice should so state. 
SECTIONS OF 

WORKBOOK

Worksheet 1. Contact and Methyl Bromide Request Information

Worksheet 2-D(1&2). Methyl Bromide - Baseline - Operating Costs for 2012 (Annual or Perennial)

Worksheet 6. Application Summary

Definitions

Climate Zone Map

Worksheet 2. Methyl Bromide 

2. A tab with the name “Sheet 1” will appear at the bottom of the worksheet and will be highlighted in white. Take the cursor 

and double click the “new tab”

3. By double clicking in the tab you can now rename the worksheet to the appropriate number letter designation (e.g., 3-A(1), 

3-A(1)(a), etc.)

4. To move a newly inserted worksheet, simply drag the worksheet with your mouse to the desired location.

5. Once you add a new worksheet, Excel will automatically name each subsequently added worksheet as Sheet 2, Sheet 3, 

etc... Follow the instructions above to rename the new blank worksheets as appropriate.

Inserting a blank worksheet:

1. To add additional blank worksheets in the Excel file, go to the menu line at the top of the worksheet and select “Insert” 

then “worksheet”

Worksheet 3. Alternatives

Worksheet 2-A. Methyl Bromide - Pest and Crop Information

EXCEL 

USER TIPS 

Worksheet 2-B. Methyl Bromide - Historical Use for 2008 - 2012

INSTRUCTIONS

Each worksheet number corresponds to the tab number in the electronic version of the application. 

Instructions specific to each worksheet are provided at the top of each sheet. A header row is included on 

each worksheet to include an application ID number that EPA will assign. 

Worksheet 2-C. Methyl Bromide - Crop/Crop Grouping Yield & Gross Revenue for 2008 - 2012

Worksheet 4. Emission Control

Worksheet 3-A. Alternatives - Technical Feasibility of Alternatives to Methyl Bromide

5. Again, select the top left corner of the worksheet (left of column A and above row 1) to select the entire worksheet.

6. Go to the menu line at the top of the worksheet and select “Edit” then “Paste”

Worksheet 3-B(1&2). Alternatives - Changes in Operating Costs (Annual or Perennial)

Worksheet 5. Future Research Plans

Instructions

EPA Form # 4900-136 Pre Plant

Printing worksheets

If you would like to print all worksheets that are contained in this workbook, go to the menu bar at the top of the screen and 

select "File" and then "Print." Then in the section of the menu that appears called "Print what," select "Entire Workbook."

To increase or decrease the size of the page that is viewable on the screen, go to the menu bar and select “View” and then 

“Zoom”. 

Navigating between worksheets

Copying and pasting an entire worksheet’s contents into a blank worksheet:

1. Select the worksheet to be copied by clicking on the worksheet tab at the bottom of the screen. The tab will turn white in 

color when it has been selected.

2. Select the top left corner of the worksheet (this is the space to the left of column A and above row 1. You will know that 

the entire worksheet has been selected because the row and column marks as well as the worksheet itself will change to a 

Note: This is the only way you can copy a worksheet and not lose portions of the text instructions. 

Viewing worksheets

The set of four arrows on the bottom left of the screen will help you navigate between worksheets. This is necessary to 

access the remaining worksheet tabs in the workbook that are not viewable. The two arrows with vertical lines to either the 

left or right will take you to the first worksheet and to the last worksheet respectively in the workbook. The inner two arrows 

allow you move the worksheet tabs to the right or to the left incrementally.

The two arrows on the bottom right of the screen allow you to move the worksheet that you are viewing to the right or to the 

left. This is useful if the viewable area of on the screen is smaller than the entire page that is in the worksheet.

OMB Control # 2060-0482, Expires 6/30/2015

7. Change the title row of the newly pasted worksheet from the old worksheet number to be consistent with the worksheet 

tab.

Worksheets are best viewed in "Page Break Preview." To select the view of the worksheet, go to the menu bar and select 

"View" and then "Page Break Preview." Page break preview shows only the printable area of the worksheet, with the blue 

lines that surround the screen indicating the edges of each page.

3. Go to the menu line at the top of the worksheet and select “Edit” then “Copy”.

4. Go to the blank worksheet where you want the copied information to be pasted.
Yes No

Cell 

Fax

Cell 

Fax

EPA Form # 4900-136 Pre Plant

Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time 

needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining 

information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a 

collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. Public reporting burden for this collection of 

information is estimated to average 38 hours per response and assumes a large portion of applications will be submitted by consortia on behalf of many individual users of methyl bromide. An 

agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a current OMB control number.

Date

I certify that all information contained in this document is factual to the best of my knowledge.

Signature

Is this information Confidential Business Information?

Information in this application may be aggregated with information from other applications and used by the United States government to justify claims in the 

national nomination package that a particular use of methyl bromide be considered "critical" and authorized for an exemption beyond the 2005 phaseout. 

Use of aggregate data will be crucial to making compelling arguments in favor of critical use exemptions. By signing below, you agree now to assert any 

claim of confidentiality that would affect the disclosure by EPA of aggregate information based in part on information contained in this application.

Print Name

Address

Date

Title

Agronomic

Economic

Worksheet 1. Contact & Methyl Bromide Request Information for 2016

The following information will be used to determine the amount of methyl bromide requested and the contact person for this request. It is important that we know whom to 

contact in case we need additional information during the review of the application. 

Title

Signature

If yes, the applicant assumes responsibility for the secure transmission of electronic submissions.

Applicant Name

Primary Contact

Contact Name Specialty (Check One)

Economic

Agronomic

Daytime Phone

E-mail Address

Alternate Contact

Contact Name Specialty 

Address

Daytime Phone

E-mail Address

Print Name

OMB Control # 2060-0482, Expires 6/30/2015
1. Location

2. Crop/Crop Grouping

3. Summary of Crop System

4.

5. Climate Zone 

Zones: 

(check all that apply)

6. Soil Type & Organic 

Matter

Light Medium Heavy

0 to 2 % 2 to 5 % over 5 %

7. Yes Pounds

No

8. Yes CUE #

No

9.

A

B

C

D

E

F

10.

EPA Form # 4900-136 Pre Plant

Formulation (Ratio of MB/Pic Mixture) to 

be Used for the CUE

Use Rate (lbs a.i./acre)

Total Area to be Treated with the Methyl 

Bromide or MB/Pic Formulation

If strip, then what percentage is treated 

with strip formulation? (E.g., If 30 inches 

out of a total of 60 inches are treated with 

strip, the percent is 50%)

Total Pounds Active Ingredient (a.i.) of 

Methyl Bromide

(Insert number or 

percentage of users in 

each category)

25 - 50 acres 200 - 400 acres

(check all that apply)

Year of Exemption Request 2015 (supplemental) 2016

Use: Broadcast or Strip/Bed Treatment

What is the amount of methyl bromide being requested by this application ? (Do NOT include QPS amounts)

If a consortium is submitting this application, the data should be the total for the consortium.

Range of acres farmed by growers included in this application

0 - 25 acres

50 - 100 acres

100 - 200 acres

(Enter the type of crop system used, e.g., open field [including tunnels added after treatment], permanent glasshouses 

[enclosed], open ended polyhouses, others [please describe])

over 400 acres

(Enter the state, region, or county.)

(Indicate the soil type and percent organic matter where methyl bromide would be applied.)

(Indicate the climate zone designation by reviewing the U.S. climate zone map located at the end of this workbook or online 

at http://planthardiness.ars.usda.gov/PHZMWeb.) 

1____ 2a____ 2b____ 3a____ 3b____ 4a____ 4b____ 5a____ 5b____ 6a____ 6b____ 7a____ 7b____ 8a____ 

8b____ 9a____ 9b____ 10a____ 10b____ 11____

Organic Matter:

Soil Type:

Worksheet 1. Contact & Methyl Bromide Request Information for 2016

Is this applicant eligible for Quarantine and Preshipment (QPS) uses of methyl 

bromide?

Has this applicant previously applied for Critical Use Exemption of methyl bromide?

OMB Control # 2060-0482, Expires 6/30/2015

Please explain why there may be variations in the pounds or acres treated from year to year, especially if the request is higher this year than 

in previous years:

(Include all crops/crop groupings that benefit from an application of methyl bromide in a fumigation cycle. For a definition of 

fumigation cycle see Worksheet entitled "Definitions".) 
11.

12.

12a.

13. Yes Lbs

No

14. Have you adjusted the request for the following issues? 

Regulatory Issues: Yes___ No___ Disease Pressure: Yes___ No___

Soils Issues: Yes___ No___ Other (Please Explain): Yes___ No___

Worksheet 1. Contact & Methyl Bromide Request Information for 2016

For the region where methyl bromide is being requested, if only part of the crop area is treated with methyl bromide, indicate the reason why

methyl bromide is not used in the other area. Additionally, identify what alternative strategies are used to control the target pathogens and 

weeds without methyl bromide in that area.

Please explain why methyl bromide is being requested.

Do you anticipate that you will have any methyl bromide in storage 

after January 1, 2015?

EPA Form # 4900-136 Pre Plant

If yes, please specify amount (in pounds).

Would it be feasible to expand the use of these methods to cover at least part of the crop that has requested use of methyl bromide? What 

changes would be necessary to enable this?
Worksheet Title

2-A Methyl Bromide - Crop & Pest Information

If a consortium is submitting this application, the data for this table should reflect the representative user for 

the consortium. 

The purpose of this worksheet is to determine pest infestation and crop information where methyl bromide is 

used. This forms the baseline for evaluating the impacts of using an alternative to replace methyl bromide.

2-B Methyl Bromide - Historical Use 2008 - 2012

If a consortium is submitting this application, all data should reflect the actual data for the consortium.

This worksheet provides data in actual usage for 2008-2012. 

2-C Methyl Bromide - Crop/Crop grouping Yield and Gross Revenue for 2008-2012

If a consortium is submitting this application, the data for this table should reflect the representative user for 

the consortium. 

This worksheet provides crop/crop grouping yield and gross revenue for 2008 through 2012.

The purpose of this worksheet is to determine past gross revenues when methyl bromide is used. This forms 

the baseline for evaluating the revenue impacts of using an alternative to replace methyl bromide.

2-D(1 & 2) Methyl Bromide - Baseline - Operating Costs for 2012

If a consortium is submitting this application, the data for this table should reflect the representative user for 

the consortium. 

This data is needed to estimate a baseline for operating costs in order to estimate changes in costs and the 

impact on operating profit and short-run economic viability as a result of not using methyl bromide and to 

provide required information to the international review board.

The purpose of this worksheet is to determine operating expenses when methyl bromide is used. This forms 

the baseline for evaluating the cost impacts of using an alternative to replace methyl bromide. The data 

requested are designed to help you identify how your operation would change if methyl bromide were 

unavailable, which will be shown in Worksheet 3-B. Worksheet 2-D(1) is for users with a fumigation cycle of 

less than 5 years. Worksheet 2-D(2) is for users growing perennial crops following a single fumigation at 

establishment.

In collaboration with USDA, we will estimate fixed and overhead costs across crops and regions to 

ensure consistency within the U.S. nomination.

EPA Form # 4900-136 Pre Plant

OMB Control # 2060-0482, Expires 6/30/2015

Purpose of Data: To establish a baseline estimate of crop/crop grouping yields, gross revenues and costs using 

methyl bromide. 

Instructions specific to each worksheet are located at the top of each sheet.

Worksheet 2. Methyl Bromide 
1. Crop/Crop Grouping or 

Consortium

2.

Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec

3. Fumigation and Crop 

Timeline

Beginning Fumigation Cycle

Month 

1

Month 

2

Month 

3

Month 

4

Month 

5

Month 

6

Month 

7

Month 

8

Month 

9

Month 

10

Month 

11

Month 

12

Land Preparation

Fumigation

Planting

Harvest

Fallow

Other Key Crop Steps

Other Key Pest Steps

Continuation of Fumigation 

Cycle (if needed)

Month 

13

Month 

14

Month 

15

Month 

16

Month 

17

Month 

18

Month 

19

Month 

20

Month 

21

Month 

22

Month 

23

Month 

24

Land Preparation

Fumigation

Planting

Harvest

Fallow

Other Key Crop Steps

Other Key Pest Steps

4.

Which month does your fumigation cycle start? (check only one)

Time Interval (e.g. MONTH/YEAR/SEASON)

Comments:

What is the typical soil temperature range during methyl bromide fumigation (e.g., 60-65°F)? _____to_____°F

(Indicate when fumigation, major crop and pest management practices typically occur 

by shading the appropriate cells. Show a second crop if part of the fumigation cycle. If 

the fumigation cycle is longer than one year change the months to an appropriate interval. 

These tables are for annual crops but more than one crop may benefit from one methyl 

bromide fumigation. If application covers multiple crops/crop groupings not grown 

sequentially, they will need to provide this information for all crops/crop groupings. Please 

adjust timeline as necessary. Please provide additional comments or description below

or on a separate page. Please begin the timeline with the first land preparation. For 

perennials, please begin with the year of land preparation and fumigation and indicate the 

years of production by yield or percentage of full production.)

OMB Control # 2060-0482, Expires 6/30/2015

EPA Form # 4900-136 Pre Plant

Worksheet 2-A. Methyl Bromide - Crop & Pest Information

Time Interval (e.g. MONTH/YEAR/SEASON)
5. Target Pest(s) or Pest 

Problem(s):

Pest 1

Pest 2

Pest 3

Pest 4

Pest 5

6. Pest Economic Threshold

Year

Pest 1

Pest 2

Pest 3

Pest 4

Pest 5

7. Target Pest Infestation

Pest 1 %

Pest 2 %

Pest 3 %

Pest 4 %

Pest 5 %

8. Representative User :

Threshold

(Please provide the economic threshold information for each pest. Describe year and 

source of information such as survey or expert estimate.)

Source

(Please provide descriptive factors regarding your operation.)

Acres

Average farm size

Average acres in this crop

Average area treated with methyl bromide: Acres

Describe a few crops that could follow this crop:

Source

Acres

Worksheet 2-A. Methyl Bromide - Crop & Pest Information

Specific Reasons why 

Methyl Bromide is Needed

OMB Control # 2060-0482, Expires 6/30/2015

Units (e.g. 

pests/sq ft)

Common Name Genus

(Please identify the key target pests or pest problems for which methyl bromide is reqested. 

Provide at least common name and genus and species if possible. Additional pests or pest 

problems can be provided as an attachment. Please also explain the specific reasons why 

methyl bromide is being requested for each pest [e.g., effective herbicide is available, but 

not registered for this crop; mandatory requirement to meet certification for disease 

tolerance])

Percentage of Total 

Growing Area

EPA Form # 4900-136 Pre Plant

Other descriptive factors regarding representative user:

(Please estimate the percentage of the consortia's total growing area with a moderate to 

severe problem with these pests. Describe source of information such as a survey or expert 

estimate.)
Row B:

2008 2009 2010 2011 2012

A

Total Pounds Active 

Ingredient (a.i.) of Methyl 

Bromide

B

Use: Broadcast or Strip 

Bed Treatment

C

If strip, then what 

percentage is treated with 

strip formulation? (E.g., if 

30 inches out of a total of 

60 inches are treated with 

strip, the percent is 50%)

D

Formulation (Ratio of 

MB/Pic Mixture) to be Used 

for the CUE 

E

Total Area to be Treated 

with the Methyl Bromide or 

MB/Pic Formulation

F

Use Rate (lbs a.i/acre)

Total Area to be Treated with the Methyl Bromide or MB/Pic Formulation

Enter the total actual pounds active ingredient (a.i.) of methyl bromide applied. Note: This number should be 

the total pounds a.i. applied by the individual user or the entire consortium, for the year indicated. Include only 

the pounds active ingredient of methyl bromide. Do not include the pounds of chloropicrin that may be part of 

the same product.

If strip, then what percentage is treated with strip formulation?

Use: Broadcast or Strip Bed Treatment

Row A:

Row C:

Total Pounds Active Ingredient (a.i.) of Methyl Bromide

Indicate whether broadcast or strip bed Treatment is used.

OMB Control # 2060-0482, Expires 6/30/2015

Row D:

For as many years as possible as 

shown specify:

If strip treatments are used, enter the percentage treated with strip formulation (e.g., if 30 inches out of a total 

of 60 inches are treated with strip, the percent is 50%).

Use Rate (lbs a.i/acre)

Enter the use rate in pounds a.i. of methyl bromide per area.

Row E:

Worksheet 2-B. Methyl Bromide - Historical Use for 2008-2012

Enter the formulation of methyl bromide used (e.g. MB 98:2; MB/Pic 70:30).

Formulation (Ratio of MB/Pic Mixture) to be Used for the CUE

EPA Form # 4900-136 Pre Plant

Comments:

If there is a variation (greater than 10%) in the quantity a.i., the acres treated or average application rate from year 

to year, please explain the reasons for the variation. 

What is the frequency of methyl bromide applied per area? (1x / year, 2x / year, 1x / 3 years, etc.)

_________ times per ____________

Enter the method by which methyl bromide is applied (e.g., injected at 3 inch depth, hot gas).

Row F:
Column A: 

Column B: 

Column C: 

Column D: 

Column E: 

Column F: 

Column G: 

A B C D E F G

Year Crops/Crop 

Groupings Market Category Yield Unit of Measurement Price ($)

Gross 

Revenue per 

Acre ($)

Year

Crops/Crop Groupings

Enter average prices received by the users for that crop/crop grouping and market category. Average price over all categories 

can be calculated separately, if needed.

Enter marketing categories that determine prices received, for example, grade (size, color), timeliness (early season, late 

season), or end use (fresh, processing). Itemize or aggregate these factors to the extent appropriate if lack of methyl bromide 

would affect the yields in each category. 

OMB Control # 2060-0482, Expires 6/30/2015

Yield

Gross Revenue

Price 

Enter the unit of measurement for each crop/species (lbs, cwt, carton, bin). If not by weight, specify in the comments section 

the average weight of the measure. 

Units of Measurement

Worksheet 2-C. Methyl Bromide - Crop/Species Yield & Gross 

Revenue for 2008-2012

Market Categories

Be sure to enter the year. Use as many rows as needed for each year for all the crops/crop groupings in the fumigation cycles 

from 2008 to 2012. If a fumigation cycle overlaps more than one calendar year, then the year of the fumigation cycle is the year 

methyl bromide was applied.

Enter all crops/crop groupings that benefit from methyl bromide in the fumigation cycle. If multiple crops/crop groupings are 

grown during the interval between fumigations (e.g. tomatoes followed by peppers in a single growing season, or strawberries 

followed by lettuce over 2 or 3 years) include all of the crops/crop groupings during the entire interval. 

Enter the yield per acre, or the proportion of total yields, obtained for that category. For perennial crops, please enter yields at 

full production. Be sure to indicate yields at other stages in the timeline in Worksheet 2-A.

If someone other than the applicant benefits from the application of methyl bromide in the fumigation cycle and you do not have 

the quantitative data for the crops/crop groupings grown on the same land, please indicate so in the comments section below.

Comments:

EPA Form # 4900-136 Pre Plant

If this application is for multiple crops/crop groupings (e.g. nurseries producing evergreens, deciduous, and forbs) 

please indicate the proportion of land area allocated to each crop/crop grouping.

Gross revenue per acre for each market category and or each crop/crop grouping may be calculated using the data you entered 

as price times yield. If revenue is not equal to price times yield, you may enter a different revenue amount, but please explain 

the difference in the comments section below. 
Column A: 

Column B: 

Column C: 

Column D: 

Column E: 

Harvest costs may likewise be calculated as costs per acre (Column B) plus variable costs per unit of yield (Column 

C) times yield (Column D).

Total Cost per Acre 

Unit Costs

Total Cost per Acre 

Quantity Used per Acre

Constant Cost per Acre

For harvest operations, specify costs that depend on land area, for example, picking costs, per acre of land.

Cost per Unit of Yield

For harvest operations, specify costs that depend on amount of product harvested, for example, packing material, 

per unit of produce.

Operation / Input for Perennial Crops

For perennial crops (Worksheet D(2)), we have divided the lifespan into three basic periods: pre-production 

(including establishment), initial production, and full production. Please ensure that the timeline in Worksheet 2-A 

indicates the years of each period. Operating costs should be an average of costs incurred during each period. 

Please consider expected replanting rates and indicate which year dead or poorly performing young trees would be 

replaced. You may copy columns/rows as needed if these periods need to be refined for your situation.

EPA Form # 4900-136 Pre Plant

For inputs and operations detailed in Columns B and D, total costs can be calculated as Column B times Column D. 

Otherwise, enter total cost of the input or operation. As a check, you may add up Column E to obtain an 

estimate of total variable operating costs. These will not include fixed and overhead costs, nor a return to 

the owners' labor. It should, therefore, be less than gross revenues calculated in Worksheet 2-C. If it is not, 

please explain (for example, unusually poor yields or unusually poor prices). For perennial crops, Column E 

should only be totaled for the years at full production.

For all inputs and operations detailed in Column B, please specify the unit cost. Also, indicate all costs of applying 

methyl bromide, including any material costs, for example, tarps. If custom applied and separate costs are 

unavailable, write 'custom' and enter total cost in Column E. 

For all inputs and operations detailed in Column B, please specify the units of measurement. 

Yield

For harvest operations, indicate average yields or representative yields from Worksheet 2-C.

Units

OMB Control # 2060-0482, Expires 6/30/2015

Worksheet 2-D(1&2). Methyl Bromide - Baseline - Operating Costs 

for 2012

Enter all operating costs incurred during a fumigation cycle. Users with a relatively short fumigation cycle (less than five years) 

should use version D(1); users cultivating perennial crops should use version D(2). Users with multiple crops, either on the same 

area in a single fumigation cycle or on different areas treated separately, should copy this sheet and provide costs for each crop. 

If multiple crops are cultivated sequentially following a single fumigation, replace fumigation costs in pre-plant operations with any

additional pest control costs used prior to the following crops. If a fallow season is an important part of the fumigation cycle, 

include costs incurred (for example, cultivating a cover crop) as a separate line or as a separate sheet, if costs are extensive. 

Please fill in the unshaded areas. The shaded areas can be used if the information is known.

The operations/inputs listed here are not meant to be exhaustive or representative of your specific production 

system. They are meant to provide suggestions and to help you identify how your operation would change if methyl 

bromide were unavailable. Be as precise as necessary otherwise you may aggregate operations or inputs. For 

example, specify herbicide costs if additional treatments would become necessary with the use of a methyl bromide 

alternative, otherwise you may simply specify total pesticide costs. Please specify only variable operating costs. 

This field is required only for methyl bromide. However, you may include specific amounts of other inputs or 

operations if you believe it helps to document the additional costs you would incur by using an alternative fumigant. 

Operation / Input
B C D E 

Quantity Used per 

Acre

Units 

(lbs, hours, etc) Unit Cost ($) Total Cost per Acre ($) 

Constant Cost per 

Acre ($)

Cost per Unit of 

Yield ($) Yield Total Cost per Acre ($) 

Grading / Packing / Storage

Other Costs

 Fungicide

 Nematicide

Irrigation

Harvest Operations

Labor

Hauling

Material

Labor (manual)

Fuel / Machine Labor

Other Costs

Cultural Operations

Seed / Seedlings

Fertilizer / Soil Amendments

Pesticides

 Insecticide

 Herbicide

 application

Irrigation

Other costs

Pre-plant Operations

Land preparation

Fumigation

 product (methyl bromide)

Operation / Input

OMB Control # 2060-0482, Expires 6/30/2015

EPA Form # 4900-136 Pre Plant

A

Worksheet 2-D(1). Methyl Bromide - Baseline - Operating Costs 

for 2012
A B (1) C (1) D (1) E (1) B (2) C (2) D (2) E (2) B (3) C (3) D (3) E (3)

Operation or Input

Quantity

used per 

acre

Units (lbs, 

hours, etc) Unit Cost Total Cost per Acre

Quantity

used per 

acre

Units (lbs, 

hours, etc) Unit Cost Total Cost per Acre

Quantity

used per 

acre

Units (lbs, 

hours, etc) Unit Cost Total Cost per Acre

Establishment Operations

Land preparation

Fumigation

 product

 application

Irrigation

Seedlings

Other costs

Cultural Operations

Fertilizer/soil amendments

Pesticides

 Insecticide

 Herbicide

 Fungicide

 Nematicide

Irrigation

Labor (manual)

Fuel/machine labor

Other costs

Harvest Operations

Constant 

Cost per 

Acre

Cost per 

Unit of 

Yield

Yield Total Cost

Constant 

Cost per 

Acre

Cost per 

Unit of 

Yield

Yield Total Cost

Constant 

Cost per 

Acre

Cost per 

Unit of 

Yield

Yield Total Cost

Picking/hauling

Material

Grading/packing

Other costs

OMB Control # 2060-0482, Expires 6/30/2015

EPA Form # 4900-136 Pre Plant

Worksheet 2-D(2). Methyl Bromide - Baseline - Operating Costs for Perennial Crops

PRE PRODUCTION YEARS _______ INITIAL PRODUCTION YEARS _____ FULL PRODUCTION YEARS _____
Worksheet

3-A

3-B

3-C

EPA Form # 4900-136 Pre Plant

Alternatives - Changes in Operating Costs

Worksheet 3. Alternatives - Feasibility of Alternative Pest Control 

Regimens

Title

You must complete one worksheet for each alternative. Please inset the name of the alternative in the area 

on top of the page. If you prefer, you may provide the information requested in this worksheet in a narrative 

review. However, you must fill in the information in Question #1 and #3 or we will assume no yield or quality 

loss.

Alternatives - Technical Feasibility of Alternatives to Methyl Bromide

Purpose of Data: To estimate the loss as a result of not having methyl bromide available. EPA needs 

to compare data (yields, crop/species prices, gross revenues and costs) on the use of methyl bromide 

and alternative pest control regimens.

Complete worksheet 3-A for each alternative pest control regimen. Each worksheet contains a place 

holder in the title for you to insert the name of the specific alternative pest control regimen addressed. 

You should add additional worksheets as required.

Enter all alternative pesticides and pest control methods (and associated cost and yield data) that 

would replace one treatment of methyl bromide throughout the fumigation cycle. See the Definition 

worksheet for a comprehensive definition on fumigation cycles.

OMB Control # 2060-0482, Expires 6/30/2015

If a consortium is submitting this application, the data for this table should reflect the representative user for 

the consortium. 

This data is needed to estimate changes in costs and the impact on operating profit and short-run 

economic viability as a result of not using methyl bromide and to provide required information to the 

international review board.

The purpose of this worksheet is to determine operating expenses when alternatives are used for evaluating 

the cost impacts of using an alternative to replace methyl bromide. The data requested are designed to help 

you identify how your operation would change if methyl bromide were unavailable. Worksheet 3-B(1) is for 

users with a fumigation cycle of less than 5 years. Worksheet 3-B(2) is for users growing perennial crops 

following a single fumigation at establishment.

Please include in this worksheet data for each alternative included in worksheets 3-A and 3-B.

In collaboration with USDA, we will estimate fixed and overhead costs across crops and regions to 

ensure consistency within the U.S. nomination.

Please fill out this worksheet for each alternative for which the economic evaluation would bolster 

the case that methyl bromide is needed.

Alternatives - Economic Feasibility of Alternatives to Methyl Bromide

If a consortium is submitting this application, the data for this table should reflect the representative user for 

the consortium. 
Study # 

1

2

3

4

5

Units Units

No

Market Category Quality Impact Description

Quality Loss *

Yield With 

Alternative

Describe quality impacts such as: percent smaller fruit, reduced grade, smaller plants, crop damage, disease 

vector, etc. Refer to market category question in Worksheet 2-C.

Yield with 

Methyl 

Bromide

Enter Average Loss

Study Information

Details

5

4

3

2

Details 

1

Study # (list below) Pest Being Tested

 - Label Restriction 

Regulatory Restriction 

Organic Matter Restriction

Off Site Damage (outgassing)

Other Restrictions (Describe)

 - Township Caps 

Pest Resistant To Alternative

Details

Alternative: [ Insert Alternative ]

Yield Loss & Pest Control When Comparing This Alternative to Methyl Bromide

Provide numerical estimates where possible. Add additional rows if necessary.

Attached?

* If no yield or quality loss information is given we will assume no losses. Only provide pest control information if yield or quality loss information is not available.

For the information in #1 above list: the study name, authors, publication, date, and if a copy is attached.

% Yield Loss * % Pest Control *

Soil Restriction 

Restrictions on Alternative Use This information will be used to determine the amount of methyl bromide needed.

Are there any variety or cultivar issues associated with this alternative?

EPA Form # 4900-136 Pre Plant

% of Area

OMB Control # 2060-0482, Expires 6/30/2015

Worksheet 3-A. Alternatives - Technical Feasibility of Alternatives to 

Methyl Bromide

Are there any production delays (planting/ harvesting) associated with this alternative?

Yes (If yes, please explain)
Month 

1

Mont

h 2

Month 

3

Month 

4

Month 

5

Month 

6

Month 

7

Month 

8

Month 

9

Month 

10

Month 

11

Month 

12

Month 

1

Mont

h 2

Month 

3

Month 

4

Month 

5

Month 

6

Month 

7

Month 

8

Month 

9

Month 

10

Month 

11

Month 

12

Units 

(gals, lbs. Etc.)

Fumigation

Use Rate of Chemical Alternative:

Quantity a.i. per 

Acre 

# of Acres 

Treated

# of Applications 

Active Ingredient (a.i.) Name of Product and Formulation per Year

(Indicate when fumigation, major crop and pest management practices typically occur by shading the 

appropriate cells. Show a second crop if part of the fumigation cycle. If the fumigation cycle is longer than one 

year change the months to an appropriate interval. These tables are for annual crops but more than one crop may 

benefit from one methyl bromide fumigation. If application covers multiple crops/crop groupings not grown 

sequentially, they will need to provide this information for all crops/crop groupings. Please adjust timeline as 

necessary. Please provide additional comments or description below or on a separate page. Please begin 

the timeline with the first land preparation. For perennials, please begin with the year of land preparation and 

fumigation and indicate the years of production by yield or percentage of full production.)

Alternative Timeline:

Non-Chemical Pest Control: (please describe)

Fallow

Alternative: [ Insert Alternative ]

Planting

Harvest

Fallow

Other Key Crop Steps

Other Key Pest Steps

Land Preparation

Harvest

Continuation of Alternative 

Cycle (if needed)

Beginning Fumigation Cycle Time Interval (e.g. MONTH/YEAR/SEASON)

Planting

Time Interval (e.g. MONTH/YEAR/SEASON)

Fumigation

Land Preparation

Other Key Crop Steps

EPA Form # 4900-136 Pre Plant

Comments:

Other Key Pest Steps

Worksheet 3-A. Alternatives - Technical Feasibility of Alternatives to 

Methyl Bromide

OMB Control # 2060-0482, Expires 6/30/2015
Column A: 

Column B: 

Column C: 

Column D: 

Column E: 

For inputs and operations detailed in Columns B and D, total costs can be calculated as Column B times Column 

D. Otherwise, enter total cost of the input or operation. As a check, you may add up Column E to obtain an 

estimate of total variable operating costs. These will not include fixed and overhead costs, nor a return to the 

owners' labor. It should, therefore, be less than gross revenues calculated in Worksheet 2-C. If it is not, please 

explain any variations in yields and prices. For perennial crops, Column E should only be totaled for the years at 

full production.

For all inputs and operations detailed in Column B, please specify the units of measurement. 

Yield

For harvest operations, indicate average yields or representative yields from Worksheet 3-A.

Total Cost per Acre 

Total Cost per Acre 

Harvest costs may likewise be calculated as costs per acre (Column B) plus variable costs per unit of yield 

(Column C) times yield (Column D).

EPA Form # 4900-136 Pre Plant

For all inputs and operations detailed in Column B, please specify the unit cost. Also, indicate all costs of applying 

methyl bromide, including any material costs, for example, tarps. If custom applied and separate costs are 

unavailable, write 'custom' and enter total cost in Column E. 

Cost per Unit of Yield

For harvest operations, specify costs that depend on amount of product harvested, for example, packing material, 

per unit of produce.

Unit Costs

Operation / Input for Perennial Crops

For perennial crops (Worksheet B(2)), we have divided the lifespan into three basic periods: pre-production 

(including establishment), initial production, and full production. Please ensure that the timeline in Worksheet 3-A 

indicates the years of each period. Operating costs should be an average of costs incurred during each period. 

Please consider expected replanting rates and indicate which year dead or poorly performing young trees would be 

replaced. You may copy columns/rows as needed if these periods need to be refined for your situation.

Quantity Used per Acre

This field is required only for methyl bromide. However, you may include specific amounts of other inputs or 

operations if you believe it helps to document the additional costs you would incur by using an alternative fumigant. 

Constant Cost per Acre

For harvest operations, specify costs that depend on land area, for example, picking costs, per acre of land.

Units

OMB Control # 2060-0482, Expires 6/30/2015

Worksheet 3-B(1&2). Alternatives - Changes in Operating Costs 

Enter all operating costs incurred during a fumigation cycle. Users with a relatively short fumigation cycle (less than five years) 

should use version B(1); users cultivating perennial crops should use version B(2). Users with multiple crops, either on the 

same area in a single fumigation cycle or on different areas treated separately, should copy this sheet and provide costs for 

each crop. If multiple crops are cultivated sequentially following a single fumigation, replace fumigation costs in pre-plant 

operations with any additional pest control costs used prior to the following crops. If a fallow season is an important part of the 

fumigation cycle, include costs incurred (for example, cultivating a cover crop) as a separate line or as a separate sheet, if costs 

are extensive. Please fill in the unshaded areas. The shaded areas can be used if the information is known.

Operation / Input

The operations/inputs listed here are not meant to be exhaustive or representative of your specific production 

system. They are meant to provide suggestions and to help you identify how your operation would change if 

methyl bromide were unavailable. Be as precise as necessary otherwise you may aggregate operations or inputs. 

For example, specify herbicide costs if additional treatments would become necessary with the use of a methyl 

bromide alternative, otherwise you may simply specify total pesticide costs. Please specify only variable 

operating costs. 

Alternative: [Insert Alternative]
B C D E 

Quantity Used per 

Acre

Units 

(lbs, hours, etc) Unit Cost ($) Total Cost per Acre ($) 

Constant Cost per 

Acre ($)

Cost per Unit of 

Yield ($) Yield Total Cost per Acre ($) 

Hauling

Material

Grading / Packing / Storage

Other Costs

Harvest Operations

Labor

Fuel / Machine Labor

Other Costs

 Fungicide

 Nematicide

Irrigation

Labor (manual)

Fertilizer / Soil Amendments

Pesticides

 Insecticide

 Herbicide

Cultural Operations

Seed / Seedlings

Irrigation

Other costs

Land preparation

Fumigation

 product (methyl bromide)

 application

Pre-plant Operations

Alternative: [Insert Alternative]

Operation / Input

Worksheet 3-B(1). Alternatives - Changes in Operating Costs 

A

OMB Control # 2060-0482, Expires 6/30/2015

EPA Form # 4900-136 Pre Plant
Alternative:

A B (1) C (1) D (1) E (1) B (2) C (2) D (2) E (2) B (3) C (3) D (3) E (3)

Operation or Input

Quantity

used per 

acre

Units (lbs, 

hours, etc) Unit Cost Total Cost per Acre

Quantity

used per 

acre

Units (lbs, 

hours, etc) Unit Cost Total Cost per Acre

Quantity

used per 

acre

Units (lbs, 

hours, etc) Unit Cost Total Cost per Acre

Establishment Operations

Land preparation

Fumigation

 product

 application

Irrigation

Seedlings

Other costs

Cultural Operations

Fertilizer/soil amendments

Pesticides

 Insecticide

 Herbicide

 Fungicide

 Nematicide

Irrigation

Labor (manual)

Fuel/machine labor

Other costs

Harvest Operations

Constant 

Cost per 

Acre

Cost per 

Unit of 

Yield

Yield Total Cost

Constant 

Cost per 

Acre

Cost per 

Unit of 

Yield

Yield Total Cost

Constant 

Cost per 

Acre

Cost per 

Unit of 

Yield

Yield Total Cost

Picking/hauling

Material

Grading/packing

Other costs

EPA Form # 4900-136 Pre Plant

OMB Control # 2060-0482, Expires 6/30/2015

Worksheet 3-B(2). Alternatives - Changes in Operating Costs for Perennial Crops

PRE PRODUCTION YEARS _______ INITIAL PRODUCTION YEARS _____ FULL PRODUCTION YEARS _____

[ Insert Alternative ]
1.

2008 _____ lbs/acre 2013 _____ lbs/acre

2012 _____ lbs/acre 2017 _____ lbs/acre

2008 ____ times per____ 2013 ____ times per____

2012 ____ times per____ 2017 ____ times per____

2008 _____% methyl bromide, _____% chloropicrin 2013 _____% methyl bromide, _____% chloropicrin

2012 _____% methyl bromide, _____% chloropicrin 2017 _____% methyl bromide, _____% chloropicrin

2008 2013

2012 2017

2008 2013

2012 2017

2008 2013

2012 2017

2008 2013

2012 2017

2008 2013

2012 2017

2008 2013

2012 2017

2008 2013

2012 2017

2.

Worksheet 4. Emission Control

OMB Control # 2060-0482, Expires 6/30/2015

How do you currently minimize use and/or emissions of methyl bromide, and how do you plan to further reduce use and/or 

emissions in the future?

(For all use/emissions reduction technique that you use, please fill out the text, where provided, or state the adoption rate and/or describe changes.)

What use/emission reduction methods are 

presently adopted? Please state the emission 

reduction amounts between each listed year.

What further use/emission reduction steps 

will be taken for the methyl bromide used for 

critical uses? Please project the reduction 

amounts for each year.

Less Frequent Application

Cultural Practices (please 

specify)

EPA Form # 4900-136 Pre-Plant

Methyl Bromide Rate 

Reduction

Formulation Changes 

(please specify)

If methyl bromide emission reduction techniques are not being used, or are not planned for the future, state reasons:

Tarpaulin (High Density

Polyethylene)

High Barrier Films

Virtually Impermeable Film 

(VIF)

Other Pesticides (please 

specify)

Non-Chemical Methods 

(please specify)

Other Measures (please 

specify)
1.

1 4

2 5

3

2.

1 4

2 5

3

3.

1 4

2 5

3

4.

5.

6.

7.

8.

9. Yes No

10. Yes No

11.

Years Amount ($)

12. $

Cost

13.

What is the cumulative amount spent and the types of contributions this consortium has made to fund research to develop alternatives 

to methyl bromide since 1992? (e.g. consortium dues, direct research funding, etc.) 

Name of Organization / Research Institution

Are there technologies being used to produce the crop which avoid the need for methyl bromide? Please explain whether such 

technologies could replace a proportion of proposed methyl bromide use. Yes___ No___ If yes, please describe: 

Will yield/quality loss be measured?

Will economic impacts be measured?

Prioritize the alternative chemicals or cultural practices to be tested.

Are there any other potential alternatives under development which are being considered to replace methyl bromide? Yes___ No___ 

If yes, please describe:

What would be the best currently available alternative if methyl bromide were not available?

Worksheet 5. Future Research Plans

Please describe future plans to test alternatives to methyl bromide. You may use this worksheet to describe all future plans.

Identify the top 3 to 5 target pests for your research.

Provide a list of alternative chemicals or cultural practices that have been tested.

EPA Form # 4900-136 Pre Plant

Grant requests made to USDA, EPA, state, or other funding group.

Investment

Other total investments, if any, made to reduce your reliance on methyl bromide?

OMB Control # 2060-0482, Expires 6/30/2015

(Describe each investment and its associated costs. e.g. specialized machinery, etc.)

Please provide an overview/timeline of the plan to transition away from using methyl bromide.

Please describe the management strategies that are in place or proposed to eliminate the use of methyl bromide for the nominated 

critical use, e.g., measures to avoid any increase in methyl bromide consumption, measure to encourage the use of alternatives, 

information on the market penetration of newly deployed alternatives and alternatives that may be used in the near future.
1.

2.

3.

4. 2015 lbs. 2016 lbs.

5. 2015 Acres 2016 Acres

Not 

Technically 

Feasible

Not 

Economically 

Feasible

Consortium Name:

Location:

For EPA Use Only ID # _______________

SECTOR __________________________

Worksheet 6. Application Summary

This worksheet will be posted on the web to notify the public of requests for critical use exemptions beyond the 2005 phaseout 

for methyl bromide. Therefore, this worksheet cannot be claimed as CBI. 

Crop:

Pounds of Methyl 

Bromide Requested

Acres Treated with 

Methyl Bromide

Place an "X" in the column(s) labeled "Not Technically Feasible" and/or "Not Economically Feasible" where appropriate. Use 

the "Reasons" column to describe why the potential alternative is not feasible. Please add additional rows if necessary.

Potential Alternatives Reasons

OMB Control # 2060-0482, Expires 6/30/2015

EPA Form # 4900-136 Pre Plant
Fumigation cycle: The period of time between methyl bromide fumigations.

Year: If a fumigation cycle overlaps more than one calendar year, "year" refers to the calendar year when 

methyl bromide is applied (or the beginning of the cycle).

Comparable data:

In order to compare revenues and costs with and without methyl bromide, data on alternatives for 

pest control, yields, revenues, and costs must be for the same time interval as the methyl bromide 

fumigation cycle. If, however, quantitative data, is not available for the entire fumigation cycle, then 

to be comparable, the quantitative data for the alternatives should cover the same portion of the 

fumigation cycle as the quantitative data for methyl bromide, and the rest of the cycle should be 

discussed in the comments sections.

2-year example:

If a methyl bromide fumigation is made every 2 years, then the 2003 fumigation cycle began in 2003 

and would end in 2005. The data should cover the methyl bromide costs and usage for the methyl 

bromide fumigation made in 2003, and all yields and revenues received and other costs incurred 

during the 2 year period. To be comparable, the data on alternatives should cover a similar 2 year 

period beginning at the same time of year when a methyl bromide fumigation would be made. The 

data should cover all methyl bromide alternatives used, and all yields and revenues received during 

that 2-year interval. Other pest control and other costs would only need to be provided for that 

interval if they would change from what they were with methyl bromide.

Other beneficiary 

example

If someone other than the applicant benefits from a methyl bromide fumigation, you should 

comment on these benefits if you do not have quantitative data for the entire fumigation cycle. For 

example, if a rotational crop in the second year benefits from a methyl bromide fumigation a year 

earlier, but there is quantitative data only on the first crop, then the data on the alternatives should 

cover only the first crop, and the benefits of methyl bromide and the additional pesticides that would 

have to be used on the rotational crop should be discussed in the comments sections.

Crop cycle change 

example:

If in a one year interval, methyl bromide is applied, tomatoes are grown and harvested followed by

peppers, then the fumigation cycle would be one year including the tomatoes and peppers. If, 

however, without methyl bromide, it is not possible to follow tomatoes with peppers in the same one 

year interval, then the alternative data on pesticides, costs, yields, and revenues should just cover 

tomatoes. The loss of profit from not being able to grow peppers with the alternatives would be part 

of the loss from not having methyl bromide.

Crop Grouping

The applicant can group simliar crops together if: 

(i) Crops would experience similar yield and quality losses in the absence of methyl bromide; and 

(ii) Crops are grown on the same fumigation and cultivation cycle with similar operating costs.

For example, nursery crops including various flower or tree species can be aggregated, with 

average yields per acre and prices. However, if crops are distinctly different in revenues and 

operating costs, or the cycles, the applicant may want to present yield, price and operating costs for 

each crop separately and also indicate the proportion of land area allocated to each crop.

Definitions

OMB Control # 2060-0482, Expires 6/30/2015

EPA Form # 4900-136 Pre Plant